Finality of revisional discretion bars reopening revision on a later change of opinion after conscious withdrawal.

A revisional authority that had consciously decided not to initiate suo motu revision, and had communicated that decision to the assessing authority, could not later reopen the matter on a change of opinion. The prior refusal was an active exercise of discretion under section 20, not a mere file noting, so the authority had finally concluded that the case was not fit for revision. In that situation, notice to the assessee did not arise, because the revisional process had already been dropped. The earlier precedent was distinguished on the ground that no prior decision or communication existed there. The Tribunal was therefore correct in quashing the revisional order.

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Issues: Whether the revisional authority, after consciously deciding not to initiate suo motu revision and communicating that decision to the assessing authority, could later reopen the matter and initiate revision proceedings again on a change of opinion.

Analysis: The earlier decision not to initiate revision was taken on active application of mind, was not a mere noting on the file, and had in fact been communicated to the assessing authority. In such circumstances, the question of notice to the assessee did not arise, because the authority had already concluded that the case was not fit for revision. Once that discretion under section 20 had been exercised and finally concluded, the same authority could not invoke the same power again contrary to its earlier conscious decision. The cited precedent was distinguished on the ground that there the revisional authority had not taken any prior decision and had not communicated any dropping of the proposed revision.

Conclusion: The revisional authority was not entitled to initiate revision proceedings again, and the Tribunal was correct in quashing the revisional order.

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